On November 14, 2012, the long-awaited U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) Foreign Corrupt Practices Act (“FCPA”) guidance (the “Guidance”) was released. Styled “A Resource Guide to the U.S. Foreign Corrupt Practices Act,” this 120-page document represents DOJ’s and the SEC’s effort to answer critics of the Act and to clarify their interpretation of key provisions of the Act and the principles guiding their enforcement efforts.